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PRI reporting framework 2020

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You are in Direct - Listed Equity Incorporation » ESG incorporation in actively managed listed equities » Implementation processes » (A) Implementation: Screening

(A) Implementation: Screening

LEI 04. Types of screening applied

04.1. Indicate and describe the type of screening you apply to your internally managed active listed equities.

Type of screening

Screened by


Based on data from our external data providers we perform a screening every quarter, in line with ACTIAM's Sustainable Investment Policy (including both Fundamental Investment Principles and Fundamental Material Drivers), which incorporate Environmental, Social and Governance Issues. We exclude several products and activities, for instance nuclear weapons or riverine tailings disposal. Furthermore, a sector-based score is integrated into the final ESG score, which downgrades companies that are active in certain sectors, such as the oil & gas sector. An analyst score (positive or negative) can also be given and applied by the ESG team.

Screened by


Companies that deliver sustainable goods or services, with particularly positive impacts on focus themes such as climate, land and water will receive an upgrade in their ESG score, based on the thematic overlay in the actively managed fund strategies.
Furthermore, given the varying degree of sustainability among different sectors, ACTIAM has developed sector scores into its ESG scoring methodology. Likewise to the negative/exclusionary screening approach, the ESG team can add a positive analyst score to upgrade companies.

These various (positive) screening methodologies result in higher ESG Scores for relevant individual companies.

Lastly, the mandates of our actively managed fund strategies stipulate optimising financial returns in combination with high portfolio ESG-scores relative to its benchmarks.

Screened by

          Please check the list of other international mechanisms we consult as an appendix to our Fundamental Investment Principles on our website:


ACTIAM applies a norms-based screening to all its investments, including passive funds, in which a series of relevant regulation and international norms apply to several topics. For more information, please see our Fundamental Investment Principles for both companies and sovereigns (, as well as the current exclusion lists (;

04.2. Describe how you notify clients and/or beneficiaries when changes are made to your screening criteria.

Screening criteria, which form important part of ACTIAM's Sustainable Investment Policy, are researched and proposed by the in-house ESG team. Changes to our screening criteria first have to be approved by the ESG-Committee, which consists of the CEO, CIO, the Sustainability Director and an independent ethics professor. In addition, these changes are discussed with our clients and beneficiaries. The ACTIAM ESG Committee meets on a quarterly basis and decides on the eligibility of investments and any revisions of the sustainability Policy.

Any changes and newly excluded companies are communicated on our website and in our quarterly ESG report which is published on our website and is sent to our clients. Furthermore, changes made in the past year are described in the annual report and an overview of policy updates is given. 

LEI 05. Processes to ensure screening is based on robust analysis

05.1. Indicate which processes your organisation uses to ensure ESG screening is based on robust analysis.

05.2. Indicate the proportion of your actively managed listed equity portfolio that is subject to comprehensive ESG research as part your ESG screening strategy.

05.3. Indicate how frequently third party ESG ratings are updated for screening purposes.

05.4. Indicate how frequently you review internal research that builds your ESG screens.

05.5. Additional information. [Optional]

The internal research that builds our ESG screens is reviewed as an ongoing process.

LEI 06. Processes to ensure fund criteria are not breached

06.1. Indicate which processes your organisation uses to ensure fund criteria are not breached.

          Our external accountant also verifies our processes.

06.2. If breaches of fund screening criteria are identified, describe the process followed to correct those breaches.

ACTIAM's governance is organised according to the 'three lines of defence'- model. The first line (portfolio management and the ESG research team) is the risk owner and responsible for first line risk controls. ESG criteria is integrated into mandates and underlying agreements with the clients. Mandate restrictions are monitored automatically by the mandate compliance department (the 'second line') on a continuous basis. In the event of a breach, the second line manager will investigate the cause of the breach as soon as the breach is discovered. In case of a passive breach (caused by external factors as f.i. market moves), portfolio management will realign the portfolio to the permitted bandwidth. In case of an active breach (internal factors, like f.i. an excluded security is accidentally purchased), portfolio management must sell the security immediately. The client will be informed about the event and will be compensated according to ACTIAM's compensation policy to the extent any losses have arisen. Any profits remain with the client. 

06.3. Additional information. [Optional]

In case a breach of screening criteria occurs due to a corporate action (e.g. merger, acquisition), the security will be sold when the corporate action is physically settled.